Tax Treaty Arbitration in Luxembourg

Tax Treaty dispute resolution through the Mutual Assistance Procedure (MAP) is particularly relevant in Luxembourg. Luxembourg has, as of May 2018, 81 Double Tax Convention (henceforth, “DTC”) out of which only 12 provide for arbitration clauses. In contrast, while the Arbitration procedure is also available, it is barely used in practice as the MAP procedure proves to be the most common form of resolution of tax treaty dispute resolutions in Luxembourg.